As of 25 September 2026: US Customs and Border Protection (CBP) began enforcing a rule on 18 September under which it will void an importer of record (IOR) number if the information on that importer's CBP Form 5106 is inaccurate or incomplete. A voided number is invalid "for any purpose, including entering imported merchandise into the United States." If your number, or your client's number, is voided, an entry filed under it cannot clear, including for freight already moving.
This post separates what is in CBP's own notice from what has only been reported, because the two are getting mixed together. The short version: the enforcement date and the rules on addresses, emails and phone numbers are in a Federal Register notice you can read. The number of importers affected is not published anywhere we could find.
What happened
CBP published a general notice, "Accuracy of Importer of Record Data Submitted to CBP," in the Federal Register on 19 August 2026 (91 FR 53627). It says enhanced enforcement, "including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026." The notice ties the action to Executive Order 14411, "Strengthening Customs Enforcement," signed on 3 June 2026, and to a direction in that order that DHS confirm active importers of record comply with applicable regulations.
Trade press picked it up once enforcement began. FreightWaves reported that the crackdown puts cross-border freight at risk, and cited commentary from Diaz Trade Law, which had published its own analysis of the notice in August. Both the trade-law commentary and the press coverage rest on the same underlying notice, so it is worth reading the notice itself.
A correction to a common framing
Some posts describe the voiding as coming "with no warning." That is only half right. The rule itself was announced publicly about a month ahead. What the notice does not describe is any grace period or chance to correct data on an individual number before it is voided. The notice says CBP "will issue a written notice" of a voiding to the email address the importer most recently gave CBP, and will copy the customs broker that last filed an entry for the importer, if applicable. So the individual importer learns after the fact, by email, and if that email address is wrong (or is the broker's), the notice may never reach the right person.
What CBP says counts as a defect
The notice is specific about three data points. Every one of them must be accurate, complete, and belong directly to the importer:
| Field on Form 5106 | What the notice says |
|---|---|
| Physical address | Must be the actual physical location of the business or individual. It "cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity." The form's instructions allow the business address to be the principal's home address. |
| Email address | Must be valid and belong to the importer. Brokers or third parties may not supply their own email address, or anyone else's, in its place. |
| Phone number | Must be valid and belong to the importer. Brokers or third parties may not substitute their own number. |
| EIN or SSN | The notice lists the IRS employer identification number and any Social Security number among the data that must be accurate and complete. |
The notice also reminds brokers of two obligations in the broker regulations: they must exercise due diligence and must not transmit information they know or should know is false or misleading, including anything they have not checked, and they must hold a valid power of attorney executed directly with the importer (19 CFR 111.36(c)(3)). That power of attorney cannot run through a freight forwarder or another third party.
Who is most exposed
The notice does not name any category of importer as a target. The exposure comes from common industry practice colliding with the new address, email and phone rules. Diaz Trade Law's commentary lists the arrangements it thinks are at risk, and this part is their analysis, not CBP text:
- Non-resident importers that listed a US customs broker's address because they have no US premises.
- Foreign sellers acting as importer of record on delivered-duty-paid sales.
- E-commerce sellers using third-party fulfilment centres.
- Smaller importers whose records were created years ago and never updated.
FreightWaves connected this to cross-border freight from Mexico and Canada, where foreign companies may act as non-resident importers of record for goods entering the United States. That is the press's inference about where the practice is common, not a statistic from CBP. The same commentary warns that a brokerage which put its own address, email or phone across many client records "has hundreds of potential defects." Read that as a warning about how the defect multiplies, not as a count of anything CBP has done.
What has not been reported
- How many IOR numbers have been voided. Neither CBP nor the coverage we found gives a figure. Treat any number you see quoted as unsourced.
- How many shipments are stuck. Headlines about "thousands" of shipments at risk describe exposure, and we found no source measuring actual holds.
- How long reestablishment takes. The notice says a voiding notice will explain how to request reestablishment and what identity information to send, but gives no timeline.
How the form and the regulation fit together
The legal hook is not new. Under 19 CFR 24.5, each person or firm files CBP Form 5106 (Create/Update Importer Identity Form) with the first formal entry or first request for services that results in a bill or refund. The form uses the IRS employer identification number or, failing that, the Social Security number. If neither exists, CBP assigns an importer number. A separate rule in the same section means an importer number that goes unused for a year can be removed from CBP's files, and the importer must file a new Form 5106 to transact again.
What is new is the enforcement posture. The notice says CBP is "comprehensively reviewing the CBP Form 5106 information on file for IORs for accuracy," which covers existing importers, not only new ones. Older records created under looser practice are now being read against a stricter standard.
What a voided number means on a live shipment
An entry needs a valid importer number. If the number is voided while goods are in transit, the broker cannot file or update an entry under it, and cargo that arrives at the port or the border waits. The practical costs are the ordinary ones for cargo that cannot clear: storage, demurrage and detention on containers, truck waiting time at the border, and missed delivery windows. Who pays depends on your contracts and Incoterms, which is a good reason to read them before you need them. Our customs clearance guide walks through the entry process, and the import documentation checklist covers the paperwork side.
What to check this week
If you are an importer
- Find out which importer number your entries use and ask your broker for the Form 5106 data currently on file.
- Compare each field with reality. Is the physical address where your business actually operates? Is the email an inbox you read, at your own company? Is the phone number yours? Are the EIN and legal name exact?
- Replace any broker, forwarder, registered-agent or mailbox address with your own physical address, through your broker or your assigned Center of Excellence and Expertise, using the update process on the form.
- Make sure the notice email would reach you. CBP sends the voiding notice to the most recent email address on file, so a shared or broker inbox is a risk in itself.
- Confirm your broker holds a power of attorney signed with you directly, not passed through your forwarder.
If you are a customs broker
- Audit every client record you maintain for your own address, email or phone appearing where the client's should be.
- Start with the highest-volume and non-resident clients. A voided number stops entries immediately, so triage by shipments in flight.
- Collect the client's own data and certify it only after taking steps to verify it. The notice warns the certifying party can face consequences under 18 U.S.C. 1001, and that inaccurate Form 5106 data could raise False Claims Act exposure. It also refers to broker penalties under 19 U.S.C. 1641.
- Check the power of attorney chain for each client, per 19 CFR 111.36(c)(3).
If a number is already voided
Look for the notice by email (including spam and any shared inbox), since it should state the basis for the voiding and how to request reestablishment. The notice also names an email inbox for reestablishment requests and questions, using the subject line "Enforcing IOR Accuracy." The address is printed in the Federal Register notice, and an importer or a broker holding a valid power of attorney may write to it. Have your corrected data and identity documents ready before you write.
What the notice does not settle
Two questions readers keep asking are not answered in the notice, and we would rather say so than guess.
Bonds and resident agents. The notice does not discuss customs bonds, and it does not state a new resident-agent requirement for non-resident importers. It does say a registered agent's address cannot serve as the importer's physical address. Bonds are a separate requirement for entry: see US customs bonds explained for how single-entry and continuous bonds work. Fixing Form 5106 data does not replace a bond, and a bond does not fix a defective Form 5106.
What comes next. The notice says CBP is revising importer eligibility regulations, guidance and policies under the executive order, and will announce further changes through its website and the Federal Register. We do not know what those will be. Watch those channels and your broker's advisories rather than relying on secondhand summaries, this post included. It is a snapshot as of 25 September 2026.
Why this matters beyond one form
The cost of a voided number lands on everyone in the chain: the importer whose goods stop, the broker who cannot file, the forwarder or carrier holding cargo, and the trucker waiting at the border. Importers already navigating a changed duty landscape (see US tariffs in 2026 after the IEEPA ruling) now also have an identity-data question to answer before goods move. For Mexico lanes specifically, our Mexico to USA freight guide covers the cross-border process this sits inside.
Finding help
If you need a customs broker or forwarder who handles US entries, browse the CargoLinked directory by country, city or trade lane and check each company's credentials and licences yourself, since listings are self-published. If you have a shipment to move and want quotes, you can post it on the requests board, where eligible forwarders can respond with quotes that carry a validity date.
